Hall Data Sync Technologies LLC v. Google Inc.
Filing
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Order by Hon. Vince Chhabria granting 23 Stipulation to Continue the Deadline to File the Case Management Statement.(knm, COURT STAFF) (Filed on 8/20/2015)
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[ADDITIONAL COUNSEL LISTED ON
SIGNATURE PAGE]
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Steven T. Lowe, Esq. SBN 122208
steven@lowelaw.com
Kris LeFan, Esq., SBN 278611
kris@lowelaw.com
LOWE & ASSOCIATES, P.C.
11400 Olympic Blvd., Suite 640
Los Angeles, CA 90064
Telephone: (310) 477-5811
Facsimile: (310) 477-7672
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Hao Ni (pro hac vice pending)
hni@nilawfirm.com
NI, WANG & MASSAND, PLLC
8140 Walnut Hill Lane, Suite 500
Dallas, TX 75231
Telephone: (972) 331-4600
Facsimile: (972) 314-0900
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Attorneys for Plaintiff
HALL DATA SYNC TECHNOLOGIES, LLC
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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HALL DATA SYNC TECHNOLOGY,
LLC,
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Plaintiff,
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v.
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BOX, INC.,
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Defendant.
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HALL DATA SYNC TECHNOLOGIES
LLC,
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Plaintiff,
JURY TRIAL DEMANDED
vs.
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STIPULATED MOTION AND [PROPOSED]
ORDER FOR RELIEF FROM DEADLINE TO
FILE JOINT CASE MANAGEMENT
CONFERENCE STATEMENT IN RELATED
ACTIONS PURSUANT TO L.R. 16-2(D)
Defendant.
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DROPBOX INC.
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Case Nos. 15-CV-3063-VC, 15-CV-3064-VC,
15-CV-3065-VC
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JOINT STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CMC
CASE NOS. 15-CV-3063-VC, 15-CV-3064VC, 15-CV-3065-VC
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HALL DATA SYNC TECHNOLOGIES
LLC,
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Plaintiff,
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vs.
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GOOGLE INC.
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Defendant.
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JOINT STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CMC
CASE NOS. 15-CV-3063-VC, 15-CV-3064VC, 15-CV-3065-VC
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The Parties in the above captioned cases jointly move under Civ. L.R. 16-2(d) for a
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three-day extension to the deadline to submit the Joint Case Management Conference
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Statement (“Joint CMC Statement”) to allow additional time review and submit an agreed upon
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Statement.
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Local Rule 16-2(d) provides that “a party...may seek relief from an obligation imposed
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by Fed. R. Civ. P. 16 or 26 or the Order Setting Initial Case Management Conference.” In this
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case, the Court should exercise its discretion to permit a three-day modification to the deadline
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to submit the Joint CMC Statement. The Parties in these related actions have made their best
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effort to comply with the Court’s August 12th Order (Dkt. 29 in Case No. 15-3063; Dkt. 25 in
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Case No. 15-3064; Dkt. 21 in Case No. 15-3065) setting August 18th as the deadline to submit
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the Parties’ Joint CMC Statement. Since receiving notice of the deadline, the Parties have
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discussed the contents of the Joint CMC Statement telephonically and have also exchanged an
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initial draft of the Statement. Additional time is needed, however, to allow the parties as well
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as their in-house representatives to review the Joint CMC Statement and proposed schedule,
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and to allow further time for the parties to attempt to reach agreement on its contents. The
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extension will also save the Court time and resources reviewing issues that may otherwise be
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worked out between the Parties. Moreover, lead counsel for Google has a hearing scheduled
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before the Honorable Judge Virginia Phillips in the Central District of California on August
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18th, which has made coordination on the Joint CMC Statement difficult.
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In sum, the Parties in these related actions believe that there is good cause for a short
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three-day extension and respectfully request that the Court extend the deadline to submit the
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Joint CMC Statement from August 18, 2015 to August 21, 2015. No other deadline will be
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affected by this extension (including the Case Management Conference itself).
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IT IS HEREBY STIPULATED AND AGREED, by and among the parties and their
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respective counsel of record and with the permission of the Court, that deadline to submit the
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Parties Initial Case Management Statement in this action shall be continued to Friday,
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August 21, 2015.
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JOINT STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CMC
-1-
CASE NOS. 15-CV-3063-VC, 15-CV-3064VC, 15-CV-3065-VC
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Dated: August 18, 2015
RESPECTFULLY SUBMITTED,
LOWE & ASSOCIATES, P.C.
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BY: /s/Kris LeFan___________________________
KRIS LEFAN
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ATTORNEYS FOR PLAINTIFF
HALL DATA SYNC TECHNOLOGIES, LLC
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Dated: August 18, 2015
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KASOWITZ, BENSON, TORRES & FRIEDMAN
LLP
BY: /s/__John Downing
JEFFREY J. TONEY
JONATHAN K. WALDROP
DARCY L. JONES
MARCUS A. BARBER
ROBERT P. WATKINS III
JOHN W. DOWNING
HEATHER S. KIM
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ATTORNEYS FOR DEFENDANT
GOOGLE INC.
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Dated: August 18, 2015
DLA PIPER LLP (US)
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BY: _/s/_AARON WAINSCOAT
JOHN GUARAGNA
AARON WAINSCOAT
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ATTORNEYS FOR DEFENDANT
BOX INC.
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Dated: August 18, 2015
FARELLA BRAUN + MARTEL LLP
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BY: _/s/_JEFFREY FISHER
Jeffrey M. Fisher
Deepak Gupta
Winston Liaw
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ATTORNEYS FOR DEFENDANT
DROPBOX INC.
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I hereby attest pursuant to L.R. 5.1(i)(3) that concurrence in the electronic filing of this
document has been obtained from the other signatories.
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Dated: August 18, 2015
_/s/ KRIS LEFAN______________________
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JOINT STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CMC
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CASE NOS. 15-CV-3063-VC, 15-CV-3064VC, 15-CV-3065-VC
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[PROPOSED] ORDER
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The Court having considered the stipulation of the parties, orders as follows:
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The parties shall file a Joint Case Management Statement on or before Friday,
August 21, 2015.
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PURSUANT TO THE PARTIES’ STIPULATION, IT IS SO ORDERED.
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August 20
Dated: ______________, 2015
Honorable Vince Chhabria
United States District Judge
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JOINT STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CMC
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CASE NOS. 15-CV-3063-VC, 15-CV-3064VC, 15-CV-3065-VC
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